Case Summary (G.R. No. 220451)
Factual Antecedents
The accused-appellant was charged following his alleged involvement in selling one small sachet of shabu to police officer SPO1 Ma. Nanette Puasan during a buy-bust operation, which was organized after initial surveillance activities indicated drug transactions at his residence. The prosecution argued that the transaction involved the exchange of marked money (P100 and P200 bills) for the sachet of shabu. The situation escalated with the arrest of the accused-appellant after the completion of the drug sale.
Version of the Prosecution
The prosecution’s narrative included testimonies from multiple police officers who were part of the buy-bust operation. They described a detailed account of the events leading up to the arrest of the accused-appellant, the confiscation and identification of the narcotics, and the subsequent handling of the case within the police precinct and crime laboratory. SPO1 Puasan testified to the direct exchange of marked money for the sachet of shabu, which she later marked with “AB” for identification. The subsequent examination by the forensic chemist affirmed the substance was indeed shabu.
Version of the Defense
The accused-appellant's defense contended that he had been wrongfully arrested as he was merely walking to pick up his child when police officers allegedly assaulted him. He asserted that their actions constituted a forced arrest and that he had not sold any drugs. The defense raised concerns about the credibility of the police officers’ testimonies and the handling of the evidence.
Ruling of the Regional Trial Court (RTC)
The RTC found the accused-appellant guilty, citing the testimony of the poseur buyer as credible, along with the proper handling of evidence that established the authenticity of the drug sale. He was sentenced to life imprisonment and a fine of P500,000. The RTC rejected the defense’s arguments, emphasizing the presumption of regularity in the performance of police duties.
Ruling of the Court of Appeals (CA)
On appeal, the CA upheld the RTC's decision, agreeing that the prosecution successfully demonstrated that no break in the chain of custody compromised the integrity of the seized drug. The CA reiterated that the prosecution proved the essential elements of illegal sale, asserting sufficient evidence warranted the conviction.
Our Ruling
Upon review, the Supreme Court determined that both the RTC and CA overlooked critical aspects concerning the chain of custody of the seized drug. The Court asserted that the prosecution failed to solidify a continuous chain of custody, an essential requirement under Republic Act No. 9165, which governs the handling of seized drugs. Crucial gaps were identified, including the timing and manner of marking the seized item. The absence of immediate marking and discrepancies in witness testimonies raised substantial doubts regarding the integrity of the e
...continue readingCase Syllabus (G.R. No. 220451)
Case Overview
- This case involves the appeal of Allan Bugtong y Amoroso, who was convicted by the Regional Trial Court (RTC) of Roxas City for the illegal sale of dangerous drugs, specifically methamphetamine hydrochloride or "shabu."
- The RTC sentenced him to life imprisonment and a fine of P500,000.00, which was subsequently affirmed by the Court of Appeals (CA) in its December 22, 2014 Decision.
- The primary legal issue on appeal was whether the prosecution established an unbroken chain of custody over the seized illegal drug.
Factual Antecedents
- Allan Bugtong y Amoroso was charged on January 21, 2009, for selling one small sachet of suspected shabu weighing 0.03 grams to SPO1 Ma. Nanette Puasan, a poseur buyer.
- The buy-bust operation was conducted on January 10, 2009, led by Chief of Police Leo Batiles, with several police officers participating.
- During the operation, SPO1 Puasan handed over marked money to Amoroso, who then provided her with the sachet of shabu.
- The transaction was marked by the raising of a hand signal by SPO1 Puasan, indicating the completion of the buy.
- After the arrest, the marked money was recovered from Amoroso, and the sachet was marked and inventoried by SPO1 Puasan.
Version of the Prosecution
- The prosecution presented evidence, including the surveillance conducted by SPO1 Puasan and PO2 Rodel Ibañez prior to the buy-bust operation.
- Testimonies confirmed that the sachet of shabu was marked "AB" by SPO1 Pu